On a motion for partial summary judgment, the U.S. District Court for the Southern District of Ohio rules that intercompany transactions may be excluded from gross receipts when calculating the federal research tax credit under Section 41.
Sixth Circuit reverses and remands the District Court in an unpublished opinion that also denies Proctor & Gamble’s refund claim.
Proctor & Gamble v. United States, No 08-4078 (6th Cir. Apr. 28, 2010)